United States v. Orbie Chambliss
948 F.3d 691
| 5th Cir. | 2020Background
- Chambliss was convicted in 2005 of methamphetamine trafficking and sentenced as a career offender to concurrent terms of 360 months and 240 months.
- In Sept. 2018 he was diagnosed with advanced, terminal liver cancer (initial prognosis ~2–3 months); treatment at FMC Rochester extended his life but prognosis remains terminal. He is 62 years old.
- The BOP found him eligible for compassionate release in Feb. 2019 but denied his request, citing the seriousness of the offense and his violent criminal history.
- Chambliss filed a § 3582(c)(1)(A)(i) motion for compassionate release under the First Step Act; the district court found his illness to be an extraordinary and compelling reason but denied release after weighing the 18 U.S.C. § 3553(a) factors.
- The district court emphasized Chambliss’s severe conduct, criminal history (including aggravated robbery), commission of the instant offense while on parole, and that release after 14 years would minimize the seriousness of the crime and undermine deterrence and just punishment.
- Chambliss appealed, arguing the district court abused its discretion (including by considering availability of medical care and not accounting for guideline amendments); the Fifth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in denying compassionate release despite terminal illness | Chambliss: terminal illness is an extraordinary and compelling reason and district court erred in denying relief | Gov./district court: relief is discretionary; §3553(a) factors outweigh illness; no abuse of discretion | Affirmed — district court did not abuse discretion; provided specific factual reasons and properly weighed §3553(a) factors |
| Whether consideration of the availability of effective medical care at the BOP was improper | Chambliss: need for medical care should not prolong imprisonment; analogized to Tapia | Gov./district court: noting care availability is relevant to discretionary release analysis; Tapia inapplicable because it bars lengthening sentences, not reducing them | Affirmed — court permissibly considered that FMC Rochester provides effective care; Tapia not controlling |
| Whether district court erred by not giving effect to guideline amendments (career-offender/drug guidelines) | Chambliss: changes to guidelines should have influenced release decision | Gov./district court: district court considered offense seriousness and record; balancing §3553(a) factors is discretionary | Affirmed — court adequately articulated reasons; disagreement with balancing does not require reversal |
Key Cases Cited
- United States v. Chapple, 847 F.3d 227 (5th Cir. 2017) (abuse-of-discretion standard for §3582 decisions)
- Gall v. United States, 552 U.S. 38 (2007) (sentencing courts are in superior position to find facts and weigh §3553(a); appellate deference to district court’s balancing)
- United States v. Malone, 828 F.3d 331 (5th Cir. 2016) (appellate court does not substitute its judgment for district court’s discretionary balancing)
- Tapia v. United States, 564 U.S. 319 (2011) (courts cannot lengthen a prison term to promote rehabilitation; not applicable to denying reduction)